GMC Issues New Guidance for Doctors - Industry Responds

Doctors who carry out cosmetic procedures anywhere in the UK are being issued with new guidance by the General Medical Council (GMC) to make sure they provide the best possible care for patients. The guidance makes clear the ethical obligations doctors have towards patients and the standards of care they need to provide.

It has been produced following a review of the cosmetic industry in England by Professor Sir Bruce Keogh. His report highlighted the risks associated with cosmetic interventions and how patients needed greater protection.

The new GMC guidance was developed following a public consultation held between June and September 2015 and comes into force from June 2016. It covers both surgical and non-surgical cosmetic procedures.

The guidance says that doctors must:

• Advertise and market services responsibly – any advertising must be clear, factual, and not use promotional tactics, such as ‘two-for-one’ offers to encourage patients to make ill-considered decisions. It also includes a ban on offering procedures as prizes. Doctors must not allow others to misrepresent their services.
• Give patients time for reflection – make sure they have the time and information about risks, to decide whether to go ahead with a procedure. Patients should not feel rushed or pressured.
• Seek a patient’s consent themselves – the doctor carrying out a cosmetic procedure is responsible for discussing it with the patient, providing them with the information and support they need, and for obtaining their consent. This responsibility must not be delegated.
• Provide continuity of care – the doctor must make sure patients know who to contact and how their care will be managed if they experience any complications, and that they have full details of any medicines or implants.
• Support patient safety – making full and accurate records of consultations, using systems to identify and act on any patient safety concerns, and contributing to programmes to monitor quality and outcomes, including registers for devices such as breast implants.

Professor Terence Stephenson, Chair of the GMC, said: “Cosmetic interventions should not be entered into lightly or without serious considerations. Above all, patients considering whether to have such a procedure need honest and straightforward advice which allows them to understand the risks as well as the possible benefits.

It is a challenging area of medicine which deals with patients who can be extremely vulnerable. Most doctors who practise in this area do so to a high standard but we do sometimes come across poor practice, and it is important that patients are protected from this and that doctors understand what is expected from them.

Our new guidance is designed to help drive up standards in the cosmetic industry and make sure all patients, and especially those who are most vulnerable, are given the care, treatment and support they need.”

Health Minister Ben Gummer said: “Anyone who chooses to have a cosmetic procedure should expect to have high quality and safe clinical care. This new guidance for doctors is an important step forward in improving standards and ending the lottery of poor practice in parts of the cosmetic industry.”

Professor Sir Bruce Keogh, National Medical Director, NHS England, said: “The GMC’s new guidance will play a pivotal role in raising standards and protecting people who choose to have a cosmetic procedure. The independent review I chaired, following the PIP breast implant scandal, highlighted major problems with unsafe practices in the cosmetic sector, including poor follow-up care and record keeping, and misleading and inappropriate advertising and marketing techniques. This addresses these issues and will drive safer care, more ethical practice and, overall, a better experience for people undergoing cosmetic procedures. It will also help ensure doctors are seen to be open and honest, that they work within their competence and seek appropriate training and advice where necessary. This marks an important step forward for patient protection across a wide range of cosmetic and lifestyle procedures, including areas such as laser eye surgery.”

Catherine Kydd has campaigned for better regulation of the cosmetic industry after she was given PIP breast implants. She welcomed the new guidance, saying: “Patients have a right to expect to be safe at the hands of any doctor carrying out a cosmetic procedure. The GMC’s new guidance will significantly strengthen the protection patients have, and make it easier for them to seek action if things do go wrong. It’s a big step forward for patients.”

The GMC is working closely with the Royal College of Surgeons (RCS), which is also publishing its own set of professional standards, specifically for cosmetic surgery, which will supplement the GMC’s guidance.

Stephen Cannon, Vice President of the RCS and Chair of the Cosmetic Surgery Interspecialty Committee, said: “Our professional standards for cosmetic surgery, coupled with the GMC’s new guidance, will raise the bar and make absolutely clear what we expect of all surgeons working in the private sector. The message to surgeons and doctors working in the cosmetic surgery industry is simple: if you are not working to the surgical standards we have set out today, you should not be treating patients at all. We, and regulators including the GMC, will do everything in our powers to protect patients and to stop unscrupulous individuals from practising.”

Later this year the RCS will also launch a new certification scheme, allowing patients to more easily search for a surgeon who has the necessary skills and experience to perform the procedure they are considering. Details of all UK doctors, including any specialisms they have, are published on the GMC’s online List of Registered Medical Practitioners. The GMC is continuing to explore how additional information about doctors and their qualifications, in areas such as cosmetic practice, can be made available to patients via the register. This may require legislative change, and was the subject of a public consultation by the GMC in 2015.

In addition, the GMC is currently developing a guide for patients considering cosmetic procedures, which will give advice and information on things to consider and the questions they should ask their doctor.

Full details of the GMC’s new guidance for doctors carrying out cosmetic procedures is available at www.gmc-uk.org/cosmetic.

Industry Reaction…

Deputy President of the British Association of Plastic, Reconstructive and Aesthetic Surgeons (BAPRAS), David Ward, a consultant surgeon who also sits as Deputy Chair of the RCS Cosmetic Surgery Interspecialty Committee (CSIC) said: “BAPRAS is very pleased to have been involved in the extensive work done by the RCS and GMC to ensure the highest standards of patient safety and care in cosmetic surgery. These documents represent a collaboration between organisations and surgical specialities to ensure that all surgeons adhere to rigorous professional standards. We welcome the call for better regulation of cosmetic surgery and believes a robust framework that includes pre-operative consultation, the opportunity for a second consultation and time for reflection is required to protect every patient. BAPRAS fully supports regulation of cosmetic surgery and better protection of cosmetic surgery patients. BAPRAS continues to emphasise that cosmetic surgery should only be performed when it’s the right thing for the patient and done only by surgeons fully trained in cosmetic surgery./”

Mr Nilesh Sojitra, Director of Cosmetic Surgeons London said; “The guidance is long overdue. This is something that we have campaigned for, particularly with one of the organisations that I am a member of; BAAPS - the British Association of Aesthetic Plastic Surgeons - has been talking for some time about BOGOF offers and inducements to get particularly young people in for cosmetic procedures, both surgical and non-surgical.”

Mr. Rajiv Grover, Past-President of BAAPS and Consulting Room Advisor said: “I was pleased to see the steps taken by the GMC to safeguard patients undergoing cosmetic treatments. This regulation will go a long way to making the cosmetic sector a safer environment for patients embarking on their journey to rejuvenate and enhance. The two most valuable tools in plastic surgery experience and having an aesthetic eye. When I was a trainee in plastic surgery, I remember a senior professor telling me that, although the training programme lasted six years and it would take that long to learn how to perform the operations, it would take at least 20 years to learn when to do them and when to say no to a certain patient. He was right! Surgery is no quick fix. It sounds surprising, but I turn away around 40% of patients. The other essential tool, the aesthetic eye, reminds us that we owe a lot to the teachings of great artists such as Leonardo da Vinci.”

Miss Caroline Mills, Consultant Maxillofacial Surgeon at The Face Surgeons on Wimpole Street, London said: “Robust regulation for cosmetic surgery is vital to protect patients and help them identify a highly trained surgeon. More and more people are using cosmetic surgery and it is essential they access the right information easily to help them make an informed choice about treatment and practitioner. I also welcome the decision by the RCS to develop certification in consultation and across all specialities for peripatetic surgeons from abroad working in the private sector and who are not covered by the new standards. The new self-regulation framework is an important step to ensure agreed professional standards for facial surgeons working across the healthcare sector."

Katherine Murphy, Chief Executive of the Patients Association, said: “It is vital that patients understand the risks involved with such procedures and that they feel fully informed when making the choice to undertake cosmetic surgery. Patients should be provided with all relevant information needed to guide their decisions, and they should feel able to ask questions that will reassure them. It is essential that they are supported and feel empowered to give informed consent.”

Lisa Mason, Head of Medical Standards, sk:n said: “In an industry that lacks government regulation, sk:n is delighted to see the new guidance the General Medical Council has published, which come into effect 1st June 2016. We are also in full support of the GMC’s launch of a patient guide and case studies to support this guidance which will allow patients the opportunity to make informed decisions about who they allow to perform their cosmetic treatments. At sk:n we see many people attend our clinics who been to other establishments, have trusted a cosmetic practitioner to help them and then when things have gone wrong, because the practitioner was poorly trained or was performing the treatment in unsuitable premises, they have received no support or aftercare. sk:n has always promoted good clinical practice in a safe, clinical environment with insured and properly trained practitioners. We recognise the need to constantly review our policies and procedures to provide gold standard levels of care and support.

sk:n has championed the recommendations made by Sir Bruce Keogh in his Review of the Regulation of Cosmetic Surgery 2013, which addressed areas such as informed consent, redress in the event of harm and the ability of staff. The review highlighted major risks associated with cosmetic interventions when performed in unsafe premises by untrained practitioners.

sk:n is very proud to be a member of Treatments You Can Trust, which developed a set of best practise standards for injectable treatments which cover the essential elements of medicine safety, infection control, education and training. I would recommend anyone seeking an injectable treatment to visit a clinic that is registered with TYCT who will have been independently assessed and been found to comply with the standards for these types of treatments.”

A statement from the Medical Defence Union (MDU) said; “New standards from the GMC for doctors carrying out cosmetic procedures will apply to a wide range of clinicians, not just plastic surgeons. The increasing popularity of non-surgical cosmetic treatments such as botulinum toxin and dermal fillers means many doctors now offer cosmetic procedures to patients. Almost 20% of cosmetic intervention cases notified to the MDU over the last 10 years involved non-surgical procedures, with a significant number of the enquiries from GPs and other non-surgical specialties considering extending their practice to these areas. Doctors carrying out any procedure or treatment with the primary objective of changing an aspect of a patient's physical appearance, need to be aware of and follow the new guidance. Before starting to offer cosmetic treatments, doctors should also check with their medical defence organisation to ensure they have appropriate indemnity in place for the work they are doing.”

Rachel Gardner, President of the Girls Brigade and part of the Christian young people's charity Youthscape said: "My big concern is not just how this affects adults, but how young people are engaging with how they feel about themselves. I'm all for the cosmetic surgery industry thinking about how they make it too easy for young people to have cosmetic surgery, but I think it has to be more than simply what they do. For young people particularly who are feeling incredibly vulnerable when it comes to their body image, I think decisions that are too easy can make life very difficult for young people. Having these stopgaps in place, and time to stop and think, will help some young people ask the big questions about 'where actually does my self-esteem come from?'."